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SRS Implementation Green Paper Submission Xtra

MARCH 22, 2001

Executive Summary

Xtra suggests that any implementation of a shared registry system within the .nz ccTLD should be carried out with the minimum amount of change necessary in order to provide business continuance and to deliver a high standard of service to end customers (the Registrants). Xtra would support redesigning the Registry from scratch only if the existing interfaces remain.

Should Domainz become a Registrar in a competitive environment, Xtra recommends changes to existing systems to implement the new Shared Registry System should not create unnecessary difficulties for other businesses seeking to become Registrars themselves as this could be seen as potential moves to impede competition in the market place.

Xtra proposes that we may seek to become a Registrar on behalf of our existing and future domain name customers (around 14,000). We propose ISOCNZ facilitate an SRS implementation that enables other businesses seeking to become registrars to achieve this with minimum disruption to existing processes, its customer base, and, if possible, at a minimum cost.

Key Issues

1. How to remove the Registry function from Domainz

The removal of the Registry function from Domainz should be achieved with minimal disruption to current users of the Domainz automatic registration process. It could potentially be uneconomic in terms of cost, time, and staff resources for potential Registrars to re-engineer their current processes if the registration function differs from the current one.

Xtra recommends the Domainz email template process be retained, and supplied free of charge or licensed to all Agents who wish to become Registrars. Should this interface remain exclusive to Domainz, when many ISPs and other Domainz Agents have already engineered their processes around it and would seek to become Registrars themselves, this could be seen as a move that could significantly impede competition in the market and result in decreased customer choice.

Xtra considers money spent on re-designing a new Interface when the current one works suitably for those who have chosen to adopt it through Domainz to be unnecessary

The current Interface should be seen as belonging to the Registry and not to Domainz. All Agents (and Domainz as the incumbent Registrar) who wish to become new Registrars should be enabled to use the current Interface.

If new Interfaces are required, this may prevent Agents who are currently using the automated process from moving immediately to become a Registrar. Again this could be seen as a move to significantly impede competition in the market and result in decreased customer choice, and potentially, further loss of confidence in the impartiality and transparency of ISOCNZ.

Xtra would prefer that the email template registration process continues to be employed as a means to register a domain name with the Registry. The Domainz web site Interface should be retained for use by its customers (the Registrants).

2. Operation of Domainz post split

Xtra has no view on how Domainz should operate after the Shared Registry System is implemented, provided a level playing field is in place from the beginning. How Domainz should operate is considered a matter for ISOCNZ members to resolve.

Xtra would be happy to compete with Domainz as a Registrar. However, Xtra would be concerned if the new SRS were to be implemented with significant infrastructure impediments to Xtra becoming a Registrar. Such a scenario would leave Domainz with captive customers, a significant number of them being customers of Xtra.

Xtra would also be concerned if Domainz were sold to a competitor in the Internet market as they would be purchasing Xtra's domain name customers. If the business is sold, the sale must be completed after Xtra has had time to move its customer base from Domainz to Xtra.

Xtra submits that ISPs and other providers who have registered domain names on behalf of their customers, and who wish to become Registrars, should have those customers transferred to them automatically. It is submitted that gaining the permission of Registrants to be moved will be costly and time consuming; and customer ignorance, inertia, and disinterest may preclude them from actively transferring their domain name.

At the very least, customers who registered through Xtra should be transferred automatically to Xtra unless they expressly state they want to continue to use Domainz as the Registrar of their domain name(s). That way domain name Registrants who want to remain with Domainz can opt out of the transfer process, while those customers who are not concerned about who their Registrar is can have their domain name registration and hosting services amalgamated.

Xtra believes that the majority of customers who have registered domain names through Xtra will not be concerned that Xtra is taking over the Registrar function and the current Domainz billing due to the convenience of having only one entity managing their domain name for them. Indeed, many of our customers would expect this.

An automatic transfer would also eliminate a lot of red tape, and be more time and cost effective to all concerned.

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